August 12th, 2003

To the Centers for Disease Control

To Whom it May Concern,

I wish to point out that your website makes claims concerning the safety of pesticides which cannot be “backed up” by peer reviewed research and is in violation of federal law. You state that the pesticides used in killing or repelling mosquitos are “safe when used as directed”. The EPA enforces a federal code that does not permit any vendor or applicator of these toxic chemcals to make such a misleading claim. While you are not a “vendor” per se, this statement appears to constitute malpractice since

1. No poison is safe under any circumstances and there are no safe ways to apply sprays (i.e. so that some of the spray will not enter the bodies of humans.)

2. Low dose exposures may not cause an observable reaction but it does not mean the chemical is not having adverse consequences upon the exposed party. The oxidative stress alone from processing out these ubiquitous poisons is harm by definition.

3. A very significant number of adults are easily harmed by the organophosphates which proliferate in WNV “control” because we lack an enzyme known as paroxonase (15% of adults). All babies would appear to be deficient as well until approximately 18 months of age (variable). Furthermore, levels of AchE vary widely among the populace given constant exposures to lawn chemicals and fumigants as well as medications which have anticholinergic effects. Therefore, OPs may indeed have a deleterious effect upon the central nervous system of a supposedly healthy adult with none the wiser. These are not parameters which doctors think to test in their patients.

4. It has also been shown that pesticides, in combination with other chemicals can penetrate the BBB and both pyrethroids and OPs will hyperenervate this system and can cause multisystem damage.

5. The fine mists generated in spraying remain aloft longer than usual applications and can settle deeper into lung tissue for absorption. With regard to using these chemicals “as directed”, none were developed for use in this fashion but are permitted for use in the disease prevention model…untested for the pervasive and long-lasting residues left in soil, housedust, air conditioning filters etc.

6. Physicians are unprepared to test adversely effected persons as the inert materials are rarely disclosed in these chemicals. So how do we know they are safe under any circumstances? The entire formulation lacks data for such an assertion. BTW, in N.Y. where I live, there are no laboratories issued permits so that pyrethroid and various solvent exposures can be measured in human body fluids. If one cannot test for them, how do you know no damage is occuring? How do you check on the concentrations?

Please remedy this serious breach of medical ethics. While municipalities may spray to limit liability (we know it will not really make a dent in the pest population), it is wrong to give a false sense of security to people who will then not take reasonable measures to keep themselves truly safe and avoid contact with these preparations.

Please be responsible and realize that even DEET is misleadingly advertised to the public. Yes, it serves as a repellant but so can DDT. Both are pesticides and the public should know they are slathering on a chemical which is dermally absorbed and kills smaller life forms.

Barbara Rubin

P.S. Please forgive spelling and grammatical errors. I was left mildly aphasic by pesticide poisoning and use of this form does not permit me to use a spell checker.

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